IEEPA Duty Refunds: What Importers Need to Know in 2026
Businesses that import goods into the United States may be eligible to receive refunds for certain duties collected under the International Emergency Economic Powers Act (IEEPA).
In response to court decisions concerning IEEPA duties, U.S. Customs and Border Protection (CBP) has created a new process for eligible importers to request refunds. The new system, known as Consolidated Administration and Processing of Entries (CAPE), is available through the Automated Commercial Environment (ACE) Portal.
For importers, understanding how the refund process works and taking the appropriate steps can be important to protecting their potential refund.
What Are IEEPA Duty Refunds?
The International Emergency Economic Powers Act, commonly known as IEEPA, was used to impose certain additional duties on imported goods.
Following federal court proceedings concerning these duties, CBP was directed to remove applicable IEEPA duties from qualifying entries and provide refunds.
Because of the large number of affected import entries, CBP developed CAPE to provide a more efficient way to process eligible refunds.
Rather than requiring refunds to be handled individually for every entry, CAPE allows eligible IEEPA duty refunds to be consolidated and processed through the ACE system.
What Is CAPE?
CAPE stands for Consolidated Administration and Processing of Entries.
CBP launched the first phase of CAPE on April 20, 2026. The system provides importers and authorized customs brokers with an electronic process for submitting IEEPA refund requests.
Under the initial phase, eligible Importers of Record or their authorized customs brokers can submit CAPE Declarations through the ACE Portal.
CBP designed CAPE to consolidate refunds and applicable interest instead of processing qualifying refunds on an entry-by-entry basis.
Why ACH Enrollment Matters
One of the most important steps for businesses expecting an IEEPA refund is making sure the appropriate ACH refund information is established.
CBP states that the Importer of Record or designated party must be enrolled for ACH refunds to help avoid delays in receiving payment.
Businesses should verify that their banking information and refund authorization are properly established in ACE.
Who May Be Eligible for an IEEPA Refund?
Eligibility depends on the specific import entries and their status within the CBP system.
The initial CAPE phase applies to certain unliquidated entries and certain entries that are within the applicable period following liquidation. CBP has continued to expand CAPE functionality as the refund process develops.
This means an importer should not assume that every entry is automatically handled the same way.
Businesses that paid IEEPA duties should review their import records and work with their customs broker and appropriate tax or trade professionals to determine which entries may qualify and what action may be required.
How Does the IEEPA Refund Process Work?
The CAPE process takes place through the ACE Portal.
Generally, the process involves:
- Confirming ACE access
The Importer of Record or authorized customs broker needs an established ACE Portal account. - Reviewing eligible entries
The importer or broker identifies entry numbers associated with IEEPA duties that may qualify for a refund. - Submitting a CAPE Declaration
Eligible entry numbers can be submitted through the CAPE functionality in ACE. - CBP reviews the entries
CBP processes the declaration and recalculates applicable duties without the IEEPA amounts. - Refund processing
Once the applicable entries are liquidated or reliquidated, refunds are consolidated for payment. - Electronic payment
CBP states that refunds are issued electronically through Automated Clearing House (ACH) payments.
What Should Importers Do Now?
If your business imported merchandise and paid IEEPA duties, now is a good time to review your records.
Consider taking the following steps:
Review Your Import Records
Identify entries where IEEPA duties were paid and determine the status of those entries.
Work With Your Customs Broker
Your customs broker may have access to the entry information and ACE tools necessary to identify and submit eligible refund claims.
Confirm ACE Access
Make sure the appropriate people within your organization have access to the ACE Portal and understand who is responsible for submitting refund requests.
Verify ACH Information
Confirm that the correct bank account information and refund authorization are established.
Keep Documentation
Maintain copies of entry summaries, duty payments, CAPE declarations, refund information and related correspondence.
Good recordkeeping can help your business track the refund process and reconcile the funds once they are received.
What About Older or More Complicated Entries?
Not every import entry will necessarily fit into the initial CAPE process.
CBP has indicated that CAPE is being developed in phases, with additional functionality being added for more complicated situations. Businesses with older, liquidated, protested or otherwise unusual entries may need to take different procedural steps to preserve or pursue their refund rights.
Because customs deadlines and procedures can affect eligibility, businesses should avoid assuming that an entry is no longer relevant simply because it was imported months or years ago.
How Doral Tax & Accounting Can Help
IEEPA duty refunds involve more than simply waiting for a check or ACH deposit.
Businesses may need to review import records, understand the financial impact of refunded duties and properly account for the funds once received.
At Doral Tax & Accounting, we help businesses understand their tax and accounting responsibilities so they can make informed financial decisions.
If your company imported goods and paid IEEPA duties, we can help you evaluate the accounting and tax considerations surrounding your potential refund and coordinate with your customs and financial professionals when appropriate.
Contact Doral Tax & Accounting to discuss your business's situation.
Frequently Asked Questions
Important: This article provides general information and is not legal, customs or tax advice for a specific situation. IEEPA refund procedures continue to develop, and businesses should verify current requirements with CBP and their qualified professional advisors.
